This action represents one of the broadest Section 301 tariff measures ever implemented, affecting countries that collectively account for approximately 99.4% of U.S. imports.

Earlier this year, USTR initiated 60 separate Section 301 investigations into whether major U.S. trading partners maintained adequate laws and enforcement mechanisms to prohibit imports produced with forced labor. Following public hearings, consultations with foreign governments, and review of more than 2,100 public comments, USTR concluded that the practices of the investigated economies are unreasonable and burden U.S. commerce.

As a result, USTR has imposed a new tariff regime intended to encourage global adoption and enforcement of forced labor import prohibitions.

How the New Tariffs Work

The new duties are divided into two tiers:

These duties apply broadly to imports from covered jurisdictions and may be assessed in addition to other applicable duties or trade remedies.

Which Countries Are Impacted?

The action applies to 60 economies, including major U.S. trading partners such as:

• China
• European Union Member States
• Canada
• Mexico
• United Kingdom
• Japan
• South Korea
• India
• Taiwan
• Vietnam

…among many others.

Because the covered countries represent approximately 99.4% of U.S. imports, most importers should expect some degree of exposure.

Available Exclusions

The USTR action includes several categories of exclusions.

The following products are not subject to the new tariffs:

1. Goods already subject to Section 232 Tariffs

2. Informational materials

3. Donations and accompanied baggage

4. Critical supply and economic impact exclusions

USTR also excluded selected products where:

• Tariffs could create domestic supply shortages
• Tariffs could disrupt the broader U.S. economy
• Goods are not available in sufficient quantities from U.S. producers
• Alternate sourcing options are not readily available
• An exclusion may encourage countries to adopt forced labor restrictions
• The tariff would not materially advance the policy objective

A detailed list of product-specific exclusions will be published within the Federal Register notice and should be reviewed carefully by importers.

Expected Impact on Importers

Many importers have been closely monitoring the expiration of the temporary Section 122 tariffs, which imposed a 10% surcharge on most imports entering the United States. The Section 122 program was implemented under emergency tariff authority and is limited by statute to 150 days. As a result, the tariff expires on July 24, 2026 and cannot be extended without Congressional action.

At the same time the Section 122 tariff expires, the USTR's new Forced Labor Section 301 tariffs become effective. The timing is significant because many of the countries previously subject to the Section 122 tariff are also covered by the new Section 301 action.

For many importers, the new tariffs may effectively replace the expiring Section 122 surcharge. However, unlike Section 122, these new duties may continue alongside existing customs duties, antidumping and countervailing duties (AD/CVD), and many existing Section 301 actions.

Increased Landed Costs

Importers should expect the same level or additional duty exposure across a wide range of commodities and sourcing regions. Existing sourcing decisions may need to be reevaluated as landed costs might increase.

Greater Supply Chain Scrutiny

The Administration has made clear that supply chain transparency and forced labor prevention remain key enforcement priorities. CBP continues to actively enforce Section 307 of the Tariff Act through Withhold Release Orders (WROs) and forced labor investigations.

Increased Compliance Expectations

Importers should be prepared to demonstrate:

• Supply chain traceability
• Supplier due diligence
• Country of origin accuracy
• Documentation supporting forced labor compliance efforts

These requirements align with broader CBP enforcement trends focused on reasonable care and supply chain transparency.

Woodland's Recommendation

The implementation of the Forced Labor Section 301 tariffs marks a significant shift in U.S. trade enforcement policy. While many importers may view July 24 as the end of the temporary Section 122 tariff program, the reality is that most companies will need to transition into a new tariff framework that may continue to impact landed costs, sourcing decisions, and compliance obligations.

Woodland recommends that importers proactively evaluate tariff exposure, assess supply chain risk, review available exclusions, and strengthen forced labor compliance programs to minimize disruption and protect margins.

Contact Woodland

If you would like assistance evaluating the impact of these changes on your imports, Woodland's Customs Brokerage and Global Trade Compliance teams are available to support tariff analysis, compliance reviews, supply chain assessments, and strategic duty mitigation planning.

Sources: USTR July 23, 2026 Final Action and Fact Sheet; White House Presidential Memorandum. ustr.gov, ustr.gov, whitehouse.gov